The California Supreme Court has ruled, in a 6-1 decision, that the names of peace officers who discharge their weapons on duty are presumed to be disclosable under the California Public Records Act, although concrete evidence of a specific threat to their safety may justify withholding their identities,  The case seeking access was brought by the Los Angeles Times, which carries this account of the decision by staff writer Greg Yee.

One interesting suggestion by the court's majority is that even if no threats emerge in the wake of a police shooting, the shooter's name might be withheld if he or she is an undercover officer.  It is a bit difficult to imagine how that circumstance would play out, since presumably only the officer's employer would know that he or she was an officer playing an undercover role.  To the public, all that would be known is that a so far unidentified person had fired one or more shots at someone, either missing or causing injury or death.  If asked by the press, would the employing department say that the shooter was still at large?  Being questioned as a material witness or person of interest?

In other words, the probable effort would be to keep the press and public so far in the dark about the incident that it would never occur to anyone to file a Public Records Act request for the shooter's name.  To deny disclosure on the basis of either officer safety or undercover security would be to confirm to the requester—and perhaps the wider interested public, including criminals who had crossed paths with the shooter in his or her cover identity—that the shooter was in fact a law enforcement officer.